Modern slavery and human trafficking statement for financial year

ending 31 March 2022

Organisation structure

Hamilton Fraser is a trading name of HFIS Limited, who are a subsidiary of Global Risk Partners and part of the GRP Group.

Global Risk Partners Limited (“GRP”) is registered in England and Wales under company registration number 8613882. Registered office: 7th Floor 55 Mark Lane, London, EC3R 7NE.

GRP has a number of subsidiaries and is one of the largest independent insurance intermediaries in the UK – details of all subsidiaries can be provided on request (together, the “GRP Group”).

This statement covers the activities of the GRP Group which is headquartered in London and has over 2000 teammates in subsidiaries within the United Kingdom and Republic of Ireland. As at the financial year end 31 March 2022 we did not have any subsidiaries or teammates based in other territories.

Our commitment

The GRP Group is committed to conducting its business in a fair, honest and open manner in compliance with all relevant laws and regulations. We seek to promote appropriate behaviour across all aspects of our business operations whilst ensuring fair and consistent outcomes for our stakeholders.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited. The GRP Group is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

Our supply chains

The GRP Group performs an important role in the insurance distribution chain dealing with its end customers, brokers, underwriting agents, insurers and other insurance market participants. We also deal with providers of other services necessary to run our business effectively such as IT providers.

Risk assessment

We believe that we are at low risk of human trafficking and slavery occurring within our business or supply chain. Our operations are primarily office based requiring skilled teammates, in a heavily regulated sector and mostly in the UK. We do not have a supply chain that is reliant on factories or other entities that would normally be associated with slavery or forced labour. As a general rule, contractors and suppliers used by us are also not considered likely to be susceptible to this risk.

Due diligence and contracting process

Teammates responsible for managing suppliers and other firms involved with the GRP Group ensure that our values and ideals are upheld in third parties. We continue to ensure that our contracts include appropriate protections and serious violations by suppliers would lead to the termination of the business relationship.

Relevant policies

The GRP Group operates a number of policies that mitigate the risk of modern slavery and set out steps to be taken to prevent slavery and human trafficking in its operations.

Colleague code of conduct

GRP Group prides itself on being open and informative with regards to employment. We are intent on advancing equality and diversity within all our key activities and believe this to be ethically right and socially responsible. Equality and diversity are essential factors that contribute to the strength and continued growth of any business. Our Code of Conduct is contained within the colleague handbook and is accessible to all teammates.

Whistleblowing policy

We aim to ensure that all individuals working within the business feel comfortable to raise concerns and challenge poor practices and behaviours related to direct activities or in our supply chains.

This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Whistleblowing Policy is designed to make it easy for individuals to make disclosures, without fear of reprisal and includes reference to external bodies. We provide our teammates with access to an independent confidential helpline for those that wish to raise a concern. Whistleblowing posters are displayed in all premises.

All teammates undertake training on Whistleblowing and are required to read and acknowledge the GRP Group Whistleblowing Policy.

Recruitment and selection policy

We use only specified, reputable employment agencies to source labour. All subsidiaries ensure appropriate controls are in place to ensure teammates have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports.

We do not employ individuals that would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.

Basic rights which we expect all workers to enjoy, include:

The right to a reasonable wage
The right to a safe working environment
The right to an appropriate level of holiday and cover for period of sickness
The freedom to complain directly via our whistleblowing policy free of charge.

Training policy

All teammates undertake a Modern Slavery training course when joining GRP and then at least every 18 months to ensure that there is appropriate awareness within the business.

Internal audit

All GRP Group subsidiaries are subject to periodic audits. Core audit work will include an assessment of the basic working conditions of our teammates.

Corporate social responsibility

We recognise that our business doesn't exist in isolation nor is it simply a way of making money. We recognise that our teammates depend on our business being successful, that customers, suppliers and the local community are all affected by our business and what we do and the way in which we do it.

We work to understand the impact that the GRP Group has on the wider world and consider at all times, how we can use this impact in a positive way. We adopt a responsible attitude, often going beyond the minimum legal requirements and working to minimise any negative impact our business may have.

We have in place a Colleague Assistance Programme (including access to GP and counselling services). A number of Wellness surveys have been conducted during the last 12 months focusing on the wellbeing of our teammates and identifying areas for improvement. We have created a network of trained Mental Health First Aiders and launched a new flexible benefits platform including various benefits to support the mental and physical health of our teammates and their families.

Approval – 22 September 2022

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the GRP Group’s slavery and human trafficking statement for the financial year ending 31 March 2022. This statement has been approved by the Global Risk Partners Limited board of directors, who will review and update it annually.

Mike Bruce

Chief Executive, GRP Group